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In March, the U.S. Department of Justice (DOJ) issued revised guidance for the Foreign Corrupt Practices Act’s (FCPA) Corporate Enforcement Policy (CEP) concerning the adoption of rules and regulations around the use of ephemeral messaging platforms, such as Snapchat, WeChat or Telegram for business...
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This year is the 20th anniversary of the implementation of the OECD’s Anti-Bribery Convention. So, we went to Paris to meet Patrick Moulette, Head of the OECD Anti-Corruption Division. He explained that the global spread of negotiated settlements, particularly Deferred Prosecution Agreements, prompted...
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Forget about the turtles. Today is International Ninja Day, but what we’re on about has more to do with regulatory risk than teenagers or (as far as we know) mutants. Why does International Ninja Day make us think ‘compliance program’?
International Ninja Day was the brainchild of...
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Petrobras has reached a $1.78 billion settlement with the DOJ and SEC over bribes to politicians and political parties in Brazil. This is the first time an enforcement action over FCPA violations has exceeded a billion dollars. The amount is bigger than the nearest two settlements combined, and the case...
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Just three years ago, Teva Pharmaceuticals, a drug-maker in Israel, disclosed to both the U.S. Securities & Exchange Commission and the U.S. Department of Justice that an on-going internal probe had revealed possible violations of the Foreign Corrupt Practices Act (FCPA) and/or local laws. Ultimately...
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